Customs Proposes To Substantially Transform The Substantial Transformation Test
Client Alert | less than 1 min read | 08.08.08
By Notice of Proposed Rulemaking, 73 Fed. Reg. 43385 (July 25, 2008), Customs & Border Enforcement has proposed substituting, for many purposes including rulings under the Trade Agreements Act (TAA), a "tariff shift" approach for determining country of origin in lieu of the longstanding and subjective "case-by-case" approach to determining the place where "substantial transformation" occurred. Under the proposed rule, contractors selling products under the contracts subject to the TAA would have to reevaluate their products under the rigid, pre-established formulaic tariff shift analysis to ensure products with significant non-designated country content qualify for sale to the federal government.
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Client Alert | 6 min read | 11.03.25
ICE Is Suddenly At The Door: How Retailers, Hospitals, And Hotels Can Survive The Surprise Visitor
Imagine a typical morning at your retail store, hospital, or hotel—customers are arriving, staff are busy, and suddenly, federal agents from ICE appear at your front desk. The surprise is real, but panic does not have to be. Unannounced inspections conducted by Immigration and Customs Enforcement (ICE) inspectors have been occurring for years, but in recent months, ICE has ramped up inspection visits across the service sector, targeting I-9 compliance and employment records. These visits are not always dramatic raids; more often, they are routine checks that can escalate if your team is not prepared.
Client Alert | 6 min read | 11.03.25
Client Alert | 13 min read | 10.30.25
Federal and State Regulators Target AI Chatbots and Intimate Imagery
Client Alert | 3 min read | 10.30.25
Is Course Hero Heading to Summer School After Summary Judgment Loss?
